1. All of the plaintiffs' claims are dismissed.

2. The costs of lawsuit are assessed against the plaintiffs.

Details of the disposition

Plaintiff C’s 21,00-42,500-4,934,875,000- D 24,1514,970-4,65,9701-4,657,813,500 Plaintiff B’s spouse 4,607,607, 654,194,00-E 5,212740,7404,104,000-si and 5,212740,104,000-si and 59,05247,47,470,566,500-10,630-10-2, the aggregate of the market price of Plaintiff and A’s father, mother, and 50-25,000-2,00-2,00-5,000-3,00-6,05,000-6,05,00-7,0.

The plaintiffs transferred the shares of the non-party company around 2012, but did not report and pay the transfer income tax.

The Defendant, on September 10, 2015, issued a notice of KRW 33,221,910 to the Plaintiff on September 10, 2015, on the ground that the Plaintiff fell under the major shareholder under Article 94(1)3 (a) of the former Income Tax Act (amended by Act No. 12738, Jun. 3, 2014; hereinafter “former Income Tax Act”) and Article 157(4)2 of the former Enforcement Decree of the Income Tax Act (amended by Presidential Decree No. 24356, Feb. 15, 2013; hereinafter “former Enforcement Decree of the Income Tax Act and the former Enforcement Decree of the Income Tax Act”) and did not report his/her shares after transferring them to others.

On December 11, 2015, Plaintiff A, and Plaintiff B, respectively, filed an appeal with the Tax Tribunal on December 15, 2015, but all of the above claims were dismissed on June 21, 2016.

Around September 2016, the Defendant conducted an investigation into capital gains tax for the year from 2010 to 2014 for the Plaintiffs, and on November 28, 2016, KRW 19,739,750 for Plaintiff A, and Plaintiff B for the year 2012.